EICR question, OLD AC RCD- code 3 or no code?

[baldelectrician]

With regards to Regulation 531.3. 3 of BS 7671:2018+A2:2022

Older AC type RCD's are prone to being blinded by dc leakage from other items plugged in to the property. In other words this RCD may fail to operate when other electronic items are plugged in which leak DC in to the mains.
Regulation 531.3. 3 of BS 7671:2018+A2:2022 states that the appropriate RCD shall be selected according to the presence of DC components and AC frequencies. Further, Type AC RCDs shall only be used to serve fixed equipment, where it is known that the load current contains no DC components.

So, do I code the old RCD as a code 3 or no code?

I am thinking of C3 as it complied before but does not comply now in many instances.


Discuss...

 

[Markyd]

No code for me......met the regs at time of install...issues will arise when addition to a circuit or new circuit is added

 

[loz2754]

We assess an installation and it's components according to the current regulations, not the regulations it was installed to previously.
The current regulations take into account changes in the way we use electrical equipment, and the evolving of the design of appliances that we plug in. More and more equipment introduces the potential of DC current leaking into the system. An RCD that potentially will fail to operate due to being blinded by DC current could cause someone to receive a fatal electric shock. Surely that deserves at least a C3.

 

[Markyd]

Still would not code it....just a note on cert that it may need upgrading in future

 

[timhoward]

C3 for me, in general the same as anything else I notice that complied once but doesn’t now.

Out of interest, slightly relating to another thread, would an oven and induction hob be considered fixed loads with no DC components? I suspect not but always worth checking!

 

[bill01803]

Definitely no code, regs are not retrospective.

 

[Dustydazzler]

Another grey area to the already 50 shades of grey coding

Retrospective / not retrospective / was fine at the time of install / is now out dated and needs changing / tests up fine / tests up fine but doesn't meet the latest version of 7671

My opinion when it comes to A/C RCDs on an existing Install , for the purposes of an EICR i would not Code it so long as it tests up fine , functions with the test buttonetc. It was installed, it met the regs at that time and is fine until further notice

 

[Pretty Mouth]

C3, improvement recommended. It doesn't comply with current regs, and doesn't offer the same protection as a type A, but it's at least a couple of fails away from being dangerous.

Incidentally I still frequently carry out minor works on circuits protected with type AC. I test them on both type AC and A settings, and if they pass both at 1X and at (the no longer required) 5X, I'm happy to go ahead.

 

[loz2754]

Another way to look at this might be that if we do not code an item as C3 because it complied at the time of installation, we are taking away the client's choice to make a significant improvement to the safety of the installation. They would be unaware of the improvements made to the wiring regulations, and of changes that are happening in the world of technology that can both contribute to safety, but also to introduce new potential hazards (in this case the DC blinding of older RCDs).
Coding it C3 at least makes the client aware that an improvement to the safety of the installation is actually an option.

 

[loz2754]

Definitely no code, regs are not retrospective.

So would you code a service head that has a fuse in both the line and neutral conductors?
After all, regs are not retrospective.

Guidance note 3 makes it clear that we assess the installation according to the current edition of the regs. The C3 code is an opportunity to make the client aware that things have changed, moved on and improved, and that they can move on with the changes if they want to.

 

[loz2754]

Another grey area to the already 50 shades of grey coding

Retrospective / not retrospective / was fine at the time of install / is now out dated and needs changing / tests up fine / tests up fine but doesn't meet the latest version of 7671

My opinion when it comes to A/C RCDs on an existing Install , for the purposes of an EICR i would not Code it so long as it tests up fine , functions with the test buttonetc. It was installed, it met the regs at that time and is fine until further notice

But did you test the RCD while the washing machine was running and leaking DC into the system? Or the EV charge point? Or some other gizmo?
If we are no longer allowed to install an AC RCD, because of the above, surely if we come across one on an EICR, we should be alerting the client to the potential danger by coding it C3.

 

[Markyd]

Another grey area to the already 50 shades of grey coding

Retrospective / not retrospective / was fine at the time of install / is now out dated and needs changing / tests up fine / tests up fine but doesn't meet the latest version of 7671

My opinion when it comes to A/C RCDs on an existing Install , for the purposes of an EICR i would not Code it so long as it tests up fine , functions with the test buttonetc. It was installed, it met the regs at that time and is fine until further notice

At last someone who knows

 

[baldelectrician]

Another grey area to the already 50 shades of grey coding

Retrospective / not retrospective / was fine at the time of install / is now out dated and needs changing / tests up fine / tests up fine but doesn't meet the latest version of 7671

My opinion when it comes to A/C RCDs on an existing Install , for the purposes of an EICR i would not Code it so long as it tests up fine , functions with the test buttonetc. It was installed, it met the regs at that time and is fine until further notice

Me and my son (who is also an electrician) were having this discussion and he said much the same as you

I then said - in that instance how would you code a voltage operated ELCB- it complied with the regs at the time of the install and you can test it with an RCD tester and the test button works so....

In my opinion we test to the current regs and make a decision to code accordingly

I was on 2 minds on RCDs that are AC type-
1. note on cert and code 3, suggest change (this is what I have been doing till now)

2. note on cert and code 2, suggest change / replacement, EICR unsatisfactory.

Will be getting my SELECT asessment on Friday so will bring it up then, in the meantime I will email NICEIC and SELECT (I am in both) and get an opinion.

 

[nicebutdim]

Me and my son (who is also an electrician) were having this discussion and he said much the same as you

Me and my son (who is also an electrician) were having this discussion and he said much the same as you

I then said - in that instance how would you code a voltage operated ELCB- it complied with the regs at the time of the install and you can test it with an RCD tester and the test button works so....

In my opinion we test to the current regs and make a decision to code accordingly

I was on 2 minds on RCDs that are AC type-
1. note on cert and code 3, suggest change (this is what I have been doing till now)

2. note on cert and code 2, suggest change / replacement, EICR unsatisfactory.

Will be getting my SELECT asessment on Friday so will bring it up then, in the meantime I will email NICEIC and SELECT (I am in both) and get an opinion.

What would be your reasoning behind option #2 in coding this C2?

 

[Dustydazzler]

Me and my son (who is also an electrician) were having this discussion and he said much the same as you

Me and my son (who is also an electrician) were having this discussion and he said much the same as you

I then said - in that instance how would you code a voltage operated ELCB- it complied with the regs at the time of the install and you can test it with an RCD tester and the test button works so....

In my opinion we test to the current regs and make a decision to code accordingly

I was on 2 minds on RCDs that are AC type-
1. note on cert and code 3, suggest change (this is what I have been doing till now)

2. note on cert and code 2, suggest change / replacement, EICR unsatisfactory.

Will be getting my SELECT asessment on Friday so will bring it up then, in the meantime I will email NICEIC and SELECT (I am in both) and get an opinion.

IF we all adopted this approach 99% of installs I come across will fail an EICR

That being said it would generate me a huge amount of business replacing loads of boards

 

[westward10]

Me and my son (who is also an electrician) were having this discussion and he said much the same as you

I then said - in that instance how would you code a voltage operated ELCB- it complied with the regs at the time of the install and you can test it with an RCD tester and the test button works so....

In my opinion we test to the current regs and make a decision to code accordingly

I was on 2 minds on RCDs that are AC type-
1. note on cert and code 3, suggest change (this is what I have been doing till now)

2. note on cert and code 2, suggest change / replacement, EICR unsatisfactory.

Will be getting my SELECT asessment on Friday so will bring it up then, in the meantime I will email NICEIC and SELECT (I am in both) and get an opinion.

Why do you think SELECT or the NICEIC will give a meaningful opinion. You are a competent person use your own judgement.

 

[Dustydazzler]

But should not we all at least have a point of reference where most of us agree what this is what a Code should be for an A/C type RCD

I do an EICR for a rental today and I say worse case RCD is code 3 so satisfactory to leave as is
Change or tenant 6 months later so new EICR
A another sparks does the EICR and Codes the same RCD code 2 needs changing forth with

We all look a bit daft

 

[pc1966]

The latest BPG#4 already has this given as C3 "A Type AC RCD installed where a Type A RCD is required" on page 19

Now we all know that BPG are guidance, not a replacement for the regs or sensible and professional assessment of the situation and real-world risk, but here it makes perfect sense to me. It could and probably should be improved which C3 implies, but equally it is not likely to present a very high risk in the majority of fault situations that C2 merits.

If it were for an EV or PV system not using SWA cable, etc, and against the MI then you might decide for C2.

Same for TT (so OCPD disconnection not likely) and if evidence of the RCD not working as expected, etc. Here the suggestion by @Pretty Mouth for testing using Type A setting on the MFT sounds reasonable, if it fails to trip in required time then C2 would be hard to argue against.

 

[nicebutdim]

C3 doesn't seem unreasonable and it's a code in which I can see logic. It won't result in an unsatisfactory report and raises a potential issue - what's not to like?

 

[westward10]

C3 doesn't seem unreasonable and it's a code in which I can see logic. It won't result in an unsatisfactory report and raises a potential issue - what's not to like?

There is nothing to say a C3 shouldn't warrant an unsatisfactory Report.

 

[nicebutdim]

There is nothing to say a C3 shouldn't warrant and unsatisfactory Report.

But that would be at the inspector's discretion?

Now that you raise this point, I can't help wondering if it is possible to issue a satisfactory report containing a C2?

 

[Markyd]

So a Landlord could have had a brand new CU fitted in August 2022 to bring him up to regs and 6 months later which would be March 2023 has a change of tenant and has a Condition report done only to be told his 6 month old RCD is a C3...........NO
Now if he has extra sockets or a new circuit fitted then that's a different matter and code

 

[nicebutdim]

So a Landlord could have had a brand new CU fitted in August 2022 to bring him up to regs and 6 months later which would be March 2023 has a change of tenant and has a Condition report done only to be told his 6 month old RCD is a C3...........NO
Now if he has extra sockets or a new circuit fitted then that's a different matter and code

Improvement recommended, due to regulatory changes. No work needs to be carried out and nothing is potentially dangerous.

Provided the inspector provides an explanation, I can't see a problem.

I'd expect more annoyance if additional work was required for the installation of a new circuit, if CU was changed last August, but coding wouldn't be a factor there.

I'd also add that, while we can not be held responsible for changes to regulations, it would have been remiss of any installer to be fitting type AC RCD protection in August 2022.

 

[loz2754]

So a Landlord could have had a brand new CU fitted in August 2022 to bring him up to regs and 6 months later which would be March 2023 has a change of tenant and has a Condition report done only to be told his 6 month old RCD is a C3...........NO
Now if he has extra sockets or a new circuit fitted then that's a different matter and code

As I have stated already, coding it as a C3 gives the client the option of improving the safety of the installation. Many landlords would want this to be made clear so that they can take responsible action.
And if they decide not to act at this time, C3 can still result in a satisfactory EICR. There has to be a point where we start to look forward in terms of keeping up to date with safety improvements, and not give in to inertia just because it might cost money.

 

[Markyd]

Improvement recommended, due to regulatory changes. No work needs to be carried out and nothing is potentially dangerous.

Provided the inspector provides an explanation, I can't see a problem.

I'd expect more annoyance if additional work was required for the installation of a new circuit, if CU was changed last August, but coding wouldn't be a factor there.

I'd also add that, while we can not be held responsible for changes to regulations, it would have been remiss of any installer to be fitting type AC RCD protection in August 2022.

Yes i agree it would be remiss....but i see this a lot because the wholesalers were knocking them out cheap to get rid of stock

 

[Dustydazzler]

C3 reminds me of the old C4

 

[nicebutdim]

Yes i agree it would be remiss....but i see this a lot because the wholesalers were knocking them out cheap to get rid of stock

And as dual boards get blown out, they'll also become quite popular. £30 + a handfull of MCBs will tempt a lot of people.

 

[nicebutdim]

C3 reminds me of the old C4

C4 used to be very common on this side of the Irish Sea, but probably a discussion for some chemistry forum.

 

[Julie.]

Improvement recommended, due to regulatory changes. No work needs to be carried out and nothing is potentially dangerous.
...

Absolutely - in just the same way when we find an installation that has the old black and red colours - due to regulatory changes we also must highlight this as a C3 - Improvement Recommended.

After all if the regulations do change making previously acceptable aspects no longer compliant, then it has to be across the board, if we must highlight one particular thing as C3 because it's non-complient we must apply this globally applying C3s on everything that is no longer completely compliant with the latest version of the regs.

Of course the customer doesn't have to address the 10-20 C3s or whatever results from the automatic C3 for anything not completely in line with the most recent regs.

OR

Should we apply engineering judgements based on the current version of the regs?

So red & black wiring, although not in line with current regs, wouldn't actually be an issue whatsoever, - changing to the new colours wouldn't really improve anything from a safety, usability, or end user point of view - so why Recommend an improvement when there actually isn't any real improvement.

Similarly, if the RCD type isn't an issue in this application again if changing it wouldn't really improve anything from a safety, usability, or end user point of view - why Recommend an improvement when there actually isn't any real improvement.

On the other hand if the RCD is on circuits that would benefit from changing the type this would be an improvement, anything from a safety, usability, or end user point of view, so deserves a C3.

On the other, other hand (?) If the RCD is actually being blocked by dc, (or clearly almost certainly will be blocked - say on a circuit where the customer uses a silly "granny charger") - then it becomes a C2


This is my problem btw with many questions about "I have x, what code?" - the answer is C1, C2, C3 or nothing for the same "issue" even on the same site depending upon the circumstances.

An easy example is "premature wiring collapse" - a drooping cable across an entrance is C1, a cable affixed, but which would drop across an exit in the event of a fire, would be C2, a cable affixed, but which would drop along a wall - out of the way in the event of a fire, would be C3, or a cable affixed, but which would drop down just a few inches - well out of harms way in the event of a fire, wouldn't attract anything.

 

[Pretty Mouth]

There is nothing to say a C3 shouldn't warrant and unsatisfactory Report.

Whist technically correct, there are many things, in the model forms and other guidance, that suggest that this is not intended, and I have found nothing that backs it up.

 

[nicebutdim]

@Julie.

My thinking, the capacity of which is limited, is that potential for issue exists due to the way in which this protective device operates and the fact that one new appliance has the potential to change that operation.

I take the above points, but believe old wiring colours aren't a good comparison as they will have no impact on a householder who doesn't tinker with fixed wiring in their home. Replacement of an old or failed appliance doesn't generally require consultation. Given that a significant number of domestic EICRs are carried out for the sole reason of complying with rental legislation, I feel this adds another layer to the issue as no one can look around the property and assume risk on the basis of appliances present at time of inspection.

Similarly, the issue of premature collapse doesn't generally involve variables - risk exists or it does not and remedial work is quite simple.

Furthermore, most inspectors who carry out EICRs won't have any means of detecting DC leakage, much less any interest in attempting to do so.

What I have taken away from this discussion is that a number of opinions in favour of not coding type AC RCDs are based on customer reaction. While I understand that position, I don't consider customer sensibilities to be a factor of testing and inspecting. It's an interesting discussion about what, on the surface, appears to be a simple issue.

 

[HappyHippyDad]

Another way to look at this might be that if we do not code an item as C3 because it complied at the time of installation, we are taking away the client's choice to make a significant improvement to the safety of the installation. They would be unaware of the improvements made to the wiring regulations, and of changes that are happening in the world of technology that can both contribute to safety, but also to introduce new potential hazards (in this case the DC blinding of older RCDs).
Coding it C3 at least makes the client aware that an improvement to the safety of the installation is actually an option.

That's an interesting way of saying 'covering my arse'

 

[pirate]

C5, anyone?

 

[pc1966]

But that would be at the inspector's discretion?

Now that you raise this point, I can't help wondering if it is possible to issue a satisfactory report containing a C2?

I think the point is C2 is an immediate "unsatisfactory" due to a clearly identified danger following a single fault, whereas C3 are not that dangerous in themselves.

But if you found an installation where practically everything was so rubbish it merited C3 you might come to the conclusion that overall it is not to a satisfactory degree of safety.

 

[nicebutdim]

I think the point is C2 is an immediate "unsatisfactory" due to a clearly identified danger following a single fault, whereas C3 are not that dangerous in themselves.

But if you found an installation where practically everything was so rubbish it merited C3 you might come to the conclusion that overall it is not to a satisfactory degree of safety.

I read more on this last night and it makes perfect sense when viewed in black and white.

 

[brianmoooore]

My interpretation is that anything that is not to the current version of the regs merits at least a C3. Every reg change should hopefully be an improvement, so anything which hasn't incorporated that improvement should be coded 'improvement recommended'.
There are many things I've installed in complete compliance with the regs that a few months later would attract a C3 on an EICR.
The plastic cased CUs in all my properties except one is an example that comes to mind, and now the type AC RCDs in those CUs.

 

[timhoward]

I then said - in that instance how would you code a voltage operated ELCB- it complied with the regs at the time of the install and you can test it with an RCD tester and the test button works so....

Going back to this point...
In almost all cases I consider this a legitimate C2, as:
...the chances are there'll be a lower impedance fault path via any metal services than via the earth rod, and the VOELCB needs current to flow via the earth rod to operate
...it will do nothing at all about a human caught between live and real earth

So we are only one step away from live parts and no ADS unless the Ra is exceptionally good.
As they were removed for safety reasons about 37 years ago I doubt I'd get as far as coding it - I'd just replace it.

Have you ever got one to trip with an RCD tester btw? I'd assume it would need more than 30ma to do anything as it's basically a solenoid.

 

[brianmoooore]

It's been decades since I came across a VOELCB, but I changed them on sight back then, so it's definitely a C2 if I found one now. They are not residual current devices, so I believe C2 is entirely justified.
Might be entirely wrong, but I have a recollection that the voltage operated devices had a resistance of around 60 ohms, so about 1.8V on the earth wire to trip it off.

 

[timhoward]

Might be entirely wrong, but I have a recollection that the voltage operated devices had a resistance of around 60 ohms, so about 1.8V on the earth wire to trip it off.

Completely academic now, I know....one of my very old books says the requirement was based on the Ze, if 200 ohms then tripping at <=24v was required and if 500 ohms it had to trip at <=40v.
The 14th Edition says the correct test is a test voltage not exceeding 45v applied to N and E on the installation side and it must trip instantaneously.
It may be that manufacturers did a lot better than the minimum requirement though!

 

[cliffed]

C3 for me & in all case’s regarding now & then situations…it covers your opinion/competence & is a recommendation for improvement in so many “grey” areas the Regs present to us those situations